Natasha's Law explained, allergen labels for UK PPDS food
Natasha's Law requires UK food prepacked for direct sale to carry its name and a full ingredients list with the 14 allergens emphasised, from 1 Oct 2021.
Natasha's Law and PPDS allergen labelling in the UK
Natasha's Law is the UK rule that food prepacked for direct sale (PPDS) must carry a label with the name of the food and a full ingredients list, with any of the 14 allergens emphasised. It has applied since 1 October 2021. Before that date, a business could give allergen information for these foods by any means, including a member of staff telling the customer (FSA).
PPDS food is packed at the same place it is sold, before the customer orders or picks it. Think of a sandwich made in the back of a café at 7am and left in the chiller for the lunch rush.
Where Natasha's Law comes from
Natasha Ednan-Laperouse was 15 when she died of anaphylaxis on 17 July 2016. She had eaten a baguette bought at Heathrow Terminal 5 that contained sesame, and the packaging gave no specific allergen information. The inquest ended on 28 September 2018. The coroner's Prevention of Future Deaths report named the PPDS labelling exemption as its first concern.
The government consulted on four options from 25 January 2019. On 25 June 2019 it announced full ingredient labelling for PPDS food. More than 70% of individual respondents backed that option. The announcement names her parents, Nadim and Tanya.
Allergens legislation behind Natasha's Law
None of the instruments below is titled Natasha's Law. Each UK nation amended its food information regulations, all in force from 1 October 2021:
| Nation | Instrument |
|---|---|
| England | SI 2019/1218. Regs 5A and 6A were later substituted by SI 2022/481 from 19 May 2022 |
| Wales | WSI 2020/295 |
| Scotland | SSI 2021/70 |
| Northern Ireland | SR 2020/80 |
In England the duty sits in the Food Information Regulations 2014. Regulation 5A requires the ingredients list on the package or a label attached to it. Regulation 6A requires the name of the food. Both are read with retained Regulation (EU) No 1169/2011 (FSA labelling guidance).
The legal definition is oddly negative. Article 2(2)(e) says "prepacked food" does not cover foods packed on the sales premises at the consumer's request or prepacked for direct sale. FIR 2014 reg 2 gives "prepacked for direct sale" that meaning. The working definition comes from FSA guidance. Scotland has its own pages from Food Standards Scotland. FSA guidance covers England, Wales and Northern Ireland.
Which food is prepacked for direct sale
The FSA defines PPDS as food "packaged at the same place it is offered or sold to consumers and is in this packaging before it is ordered or selected". Its examples include:
- sandwiches and bakery products packed on site before a customer selects them
- a burger under a hot lamp that can't be altered without opening the packaging
- pizzas, rotisserie chicken, salads and pasta pots packed on site
- burgers and sausages a butcher packs on the premises
- free samples of cookies packed on site
- food the same operator packs and sells from its own market stall or van, including food packed elsewhere
- PPDS food in schools, care homes and hospitals
The technical guidance adds two edge cases. A hot dog on an open cardboard tray isn't packaged, so it isn't PPDS. A pork pie made by one business and sold by another at a farmers' market is prepacked, so it needs full labelling.
Food that is unpackaged, or packed after the customer orders it, is non-prepacked. It needs no label, but allergen information is still mandatory and can be given verbally. Food packed by one business and supplied to another is already prepacked. For a borderline product, use the FSA's allergen and ingredients food labelling decision tool (FSA).
What PPDS labels must show
A PPDS label needs the name of the food and a full ingredients list, with the 14 allergens emphasised in the list. Article 21(1)(b) requires "a typeset that clearly distinguishes it from the rest of the list of ingredients". FSA labelling guidance adds the working detail:
- Bold type, capital letters, contrasting colours or underlining can show the emphasis.
- The list needs an "ingredients" heading.
- No separate allergen indication is needed where the name clearly refers to the allergen, such as "milk".
- Handwritten labels are allowed if they meet the legal font size requirements and are easily visible and legible.
- Alcoholic drinks over 1.2% ABV need no ingredients list. Allergens still need a "Contains:" statement, for example "Contains: wheat".
The 14 allergens
- Cereals containing gluten (wheat, including spelt and khorasan, rye, barley, oats)
- Crustaceans
- Eggs
- Fish
- Peanuts
- Soybeans
- Milk (including lactose)
- Nuts (almonds, hazelnuts, walnuts, cashews, pecans, Brazil nuts, pistachios, macadamia or Queensland nuts)
- Celery
- Mustard
- Sesame seeds
- Sulphur dioxide and sulphites above 10 mg/kg or 10 mg/litre as total SO2
- Lupin
- Molluscs
That list is Annex II. It also lists exceptions, including wheat-based glucose syrups and fully refined soybean oil. Check the annex before you emphasise a derived ingredient.
Online and phone orders
The on-pack rule doesn't cover PPDS food sold by phone or online. Allergen information must be available before the purchase is completed, in writing on a website, catalogue or menu, or orally by phone. It must also be available at delivery, in writing (an allergen sticker or an enclosed menu) or orally (FSA).
Natasha's Law posters and "may contain"
Natasha's Law does not require a poster. The FSA publishes an allergy sign and allergen matrix for non-prepacked food. PPDS food still needs the label on the pack. On 24 February 2025 the FSA published best practice recommending written allergen information plus a conversation for that food. It's not a legal requirement, and the guidance says the legal minimum "has not changed".
"May contain" labelling is still voluntary. In December 2025 the FSA Board agreed to support Codex work on a standard with allergen thresholds, subject to a gluten resolution. No UK rule has changed.
The PPDS rules are the same as after the 19 May 2022 England substitution. The FSA PPDS page was last updated on 17 July 2026, and that update only changed a decision-tool link.
Enforcement and fines
Local authorities enforce. If a business fails to act on advice, it can get an improvement notice and has 14 days to appeal. Some cases go to prosecution (FSA).
In England, failing to give the allergen particulars in reg 5A(1)(b) is an offence under FIR 2014 reg 10(1)(c). Failing to comply with an improvement notice is an offence under reg 12. The penalty is a fine not exceeding level 5 (reg 11). In England the level 5 fine is unlimited for offences after 12 March 2015 (LASPO 2012 s85). In Wales and Northern Ireland, check the national regulations. In Scotland, breaches of regs 5A(1) and 6A carry a level 5 fine of £5,000.
To check a specific product against these rules, ask RegAffairs AI, which answers with citations to the official texts.